Dynadeck Rotary Systems, LTD. - Page 6




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          to support petitioner’s claim that the Corporation executed that            
          note as the Partnership’s agent or that the Partnership was                 
          liable for the note’s repayment.  Nor is there any evidence of a            
          written agreement identifying the Corporation as the                        
          Partnership’s agent, or evidence that the Corporation was held              
          out as the partnership’s agent in dealings with LAG or another              
          third party.  See Commissioner v. Bollinger, 485 U.S. 343, 349-             
          350 (1988).                                                                 
               Our conclusion is supported by the fact that the                       
          Corporation’s role in the Partnership was to secure funds for the           
          Partnership and that the record is barren as to any obligation or           
          effort on the part of the Partnership to secure its own funds.              
          Nor do we find that any of the Partnership’s partners, except the           
          Corporation, had such an obligation.  In fact, each of the                  
          partners appears to have contributed something unique to the                
          Partnership.  In the case of Messrs. Schadeck and Lettunich, for            
          example, the former contributed his rights in the underlying                
          patent, and the latter contributed his legal skills and his                 
          labor.  The Corporation expected to, and did, generate and                  
          contribute funds to the Partnership.                                        
               We hold that the Partnership was not liable for any part of            
          the $400,000 owed to LAG and, accordingly, that no partner is               
          entitled to increase his or its basis in the Partnership on                 
          account of that debt.  We have considered all arguments for a               





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